Student Loans boss in tax scandal

Danny Alexander has ordered a review of the tax affairs of top civil servants after BBC Newsnight found that the head of the Student Loans Company (SLC) received his £182,000 salary without deductions for tax or National Insurance.

A Freedom of Information (FOI) request by Exaro News journalist David Hencke revealed that Lester's pay package was paid gross to his private service company.

The deal was signed off by Universities Minister David Willetts and it was passed to the chief secretary to the Treasury, Danny Alexander, for approval because his salary was above the Prime Minister's pay.

Alexander told Newsnight that he has now ordered an urgent inquiry across all government departments to find out how widespread this practice has been.

In spite of a government pledge to improve HMRC’s powers to stop such avoidance, HMRC appears to have agreed the arrangement when Lester was engaged on a temporary contract, and then again when he was taken on full-time, saving him an estimated £40,000 a year from his tax bill.

Lester declined to answer detailed questions about the arrangement and the SLC has claimed it "followed all government guidelines" on remuneration.

AccountingWEB members were quick to raise the IR35 spectre and found it was at the heart of this case, with dstickl asking “did Lester declare he was caught by IR35 as a ‘disguised employee’.” He added it would seem that IR35 is not being properly policed by HMRC when clear cases of employment income paid gross come to their attention.

Continued...

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Next steps: March'12 Budget IR35 clarity proposal email 2 HMT

dstickl | | Permalink

LAST YEAR: On 23rd March 2011 the Chancellor George Osborne delivered his second Budget. The then Budget documents showed his response to the Office of Tax Simplification’s earlier report on small business taxation and IR35 [legislation’s in Chapter 8, Part 2 of ITEPA 2003] as:

1.78. Following publication of the OTS review of small business tax, the Government commits to making clear improvements in the way IR35 is administered (see Chapter 2 for detail).

2.203. IR35 – Following the publication of the OTS review of small business tax, the Government commits to making clear improvements in the way IR35 is administered.

The above IR35 improvements were apparently: (a) provide greater clarity on what HMRC considered within and outside the scope of IR35 (b) simplify IR35 administration for all (c) target compliance via specialist HMRC teams restricting IR35 reviews to high risk cases (d) provide a dedicated HMRC helpline staffed by IR35 specialists (e) set up an IR35 ‘forum’ to monitor HMRC’s revised approach [NB: The Government decided it could not put substantial tax revenue at risk and hence IR35 was essentially retained].

LAST WEEK: The SLC scandal broke on BBC2TV’s Newsnight but their report failed to mention any possible IR35 impact on the alleged transgression(s).

THIS WEEKEND: (1) The Sunday Times, page 14, has a headline of “Equalities chief could avoid tax on £175,000 pay” and while the article mentions an agency and a personal service company, it appears silent on IR35.

(2) I have e-mailed the following open Budget March’12 IR35 clarification proposal to the Chancellor George Osborne on public.enquiries@hm-treasury.gov.uk<mailto:public.enquiries@hm-treasury.gov.uk>. [And plan to confirm by hard copy to The Correspondence & Enquiry Unit, HM Treasury, 1 Horseguards Road, London, SW1A 2HQ, telephone 020 7270 4558]:

 

FAO The Chancellor and his Treasury team:

This message - which is an URGENT open submission for Chancellor Osborne's March'12 Budget - is intended to help HMRC bring focus to the application of IR35.

ABSTRACT: IR35 is such a "fiscal horror" that it seems to have been forgotten or ignored by legislators etc, leading to a "Catch 22" situation that lower-paid workers are expected to sort out!   Isn't the best "legal aid" that Parliament can provide is to take lower-paid workers out of scope of IR35?

For example: In the recent SLC scandal of Mr E P Lester being paid gross (e.g. HMRC Tax Ref 2926942328 dated 14Oct'10 & "the remit of an Employer Support Team"), too many MPs and officials failed to ask: “did Lester declare he was caught by IR35 as a ‘disguised employee’?OR: "IF IR35 dues have been paid, THEN is there a story?"

Was the result that Mr E P Lester failed to pay tax etc that was "legally claimable" under IR35 legislation? Wouldn't a restricted scope to IR35 lead to better focus of effort by MPs, officials and HMRC, leading to clearer application of the rule of law (& concomitant public sector savings) and the stimulation of small businesses (& concomitant private sector economic growth)?  

For the Chancellor's & Treasury's consideration: The proposed way ahead is to introduce a further sense of economic realism to IR35, making a minimal change to S.I. 2000/727 section 7 (1) Step One to recognise the running costs of small businesses that seem to be significantly under assessed at present, thus constraining private sector economic growth whilst GDP is "flat lining".

 

PROPOSAL: A revised S.I should be introduced as part of the Budget March'12 that IR35 “should be modified so that IR35's implementing S.I. 2000/727 Section 7 (1) Step One would in future be revised to have a ‘cost allowance’ of the VAT registration threshold in cases where the worker has had a break of at least 366 calendar days since leaving a contract for service.”   These simple words could form part of the Chancellor's Budget speech!   [please see detailed S.I. wording change in "RECOMMENDATION" section below]

 

BACKGROUND:  (1) IR35 was "Originally trailed as a means of cracking down on Friday to Monday cases, where employers were sacking whole departments [on Friday], and then getting those staff to come back [on the following Monday] as independent consultants" some of whom were lower-paid workers who had urgent bills to pay, e.g. see acumen accounting website. This potential tax and NIC avoidance abuse was and is a real threat to HMRC's work and, unlike the Professional Contractors Group (PCG) etc who wish IR35 abolished, this writer believes that this IR35 rationale remains partially valid - subject to sensible restrictions being brought in to the implementing Secondary Legislation [S.I. 2000/727 section 7(1) Step One etc]. 

(2) For the very high paid, for example Directors General of the BBC who would seem to have to be employees of the BBC (otherwise how could they be seen to be leading a cohesive organisation?), the Finance Act 2000, Section 60 etc - provision of services through an intermediary - looks through intermediaries and tries to distinguish Employed and Self-employed. Its Secondary Legislation's [S.I. 2000/727 section 7(1) Step One et] current "IR35 5% costs allowance" also seems to be of a sensible order of magnitude that could address potential tax and NIC avoidance abuse at a very high level of pay.

(3) However, for the "Squeezed Middle" of aspiring small businesses, the IR35 regime introduced in Finance Act 2000, Section 60 - provision of services through an intermediary -  by secondary legislation seems to be highly problematical.   As the Tax Law Review Committee report "TAX AVOIDANCE" November 1997 states [in para 1.9 on page 2] "Avoidance, and the risk of avoidance, are at their greatest where there is a failure to base the tax on sound economic principle, where the tax creates unsustainable boundaries or where there are arbitrary rule. If governments wish to limit avoidance, they should avoid enacting legislation that positively invites it!".   In particular, the specific problem of the 2000 IR35 legislation is that "there is a failure to base the tax on sound economic principle, where the tax" fails to recognise the inevitable 'higher than 5%' inevitable running costs of small business, often recognise as the engine room of UK GDP economic growth. It should be noted that the writer - despite many verbal enquires - has been unable to establish the exact basis of the current "5%" figure with particular reference to the smaller businesses; consequently, it would appear that the "5%" figure is an arbitrary one, with the concomitant difficulties as noted by the Tax Law Review Committee in 1997. Hence an economic "simplification" of IR35 may, paradoxically, require the insertion of a few words!

(4) This ‘fiscal horror’ defect for the "Squeezed Middle" of aspiring small businesses also has societal consequences: IR35 secondary legislation as currently drafted inevitably tends to criminalise some workers - especially low paid workers and lower paid workers - because of the "Catch 22" situation that they are unable to afford the legal etc costs of skilled advocates, to fight the not straightforward IR35 statute and case law. 

 

SLC SCANDAL: You may find an article on Accounting Web about the Student Loans Company man Mr Ed Lester of interest, here's a link to it:

http://www.accountingweb.co.uk/article/student-loans-boss-spotlight-over...

More importantly ...

 

SECONDARY LEGISLATION:  (1) The IFS / Tax Law Review Committee report "Countering Tax Avoidance in the UK: Which Way Forward?" February 2009 states in part: 

* On page 45, section 13.16:   Secondary legislation [?presumably Statutory Instruments (S.I.) etc?] is generally drafted by HMRC rather than Parliamentary Counsel, although Parliamentary Counsel do scrutinise it if it amends primary legislation.  Secondary legislation is viewed as suffering from the lack of parliamentary scrutiny afforded primary legislation.  This has been seen to be a real problem in practice.

* On page 19, section 7.6:   HMRC does not have the power to legislate: taxation can only be imposed by the legislature [Article 4 Bill of Rights 1689] and while HMRC may decide upon its own interpretation of the legislation, that interpretation is not binding on taxpayers to the extent confirmed by the courts.

* On page 45, section 13.17:   If Parliament leaves the detail to be formulated by HMRC, this is widely regarded with suspicion as being subject to no parliamentary scrutiny on adoption (and potentially violating the principle that only Parliament shall impose tax) and as being open to possibly no effective challenge on appeal to the courts. 

(2) In view of (1) above, it would seem highly likely that S.I. 2000/727 section 7(1) Step One etc was drafted by HMRC in 2000, without scrutiny by Parliamentary Counsel.  This is highly problematical for Parliament, because Items (3) and (4) of the "BACKGROUND" discussion above suggests that HMRC may have drafted secondary legislation where  "there is a failure to base the tax on sound economic principle, where the tax" fails to recognise the inevitable 'higher than 5%' inevitable running costs of small business, especially in the current climate of austerity where any chance of economic growth should be encouraged - rather than suppressed by legislation that the events of the SLC (Student Loans Company) scandal has apparently shown to be forgotten or ignored by legislators, i.e. MPs, HMRC and other officials.

 

CONCLUSIONS

(1) It is now apparent that the economic implications of the words of S.I. 2000/727 section 7(1) Step One etc were not fully understood in 2000, when they were probably drafted by HMRC and were not reviewed in detail by Parliament, thus possibly transgressing Article 4 Bill of Rights 1689.

(2) In particular, the extraordinarily wide interpretation possible of the current words of S.I. 2000/727 section 7(1) Step One etc has meant that there seems to be a lack of focus by HMRC; this lack of focus seems to have resulted in a legislative lottery, as the SLC case in Central Government has shown. It should be noted that reports in Private Eye [e.g. in the "Rotten Boroughs" features ad nauseam] suggest that this legislative lottery is not necessarily restricted to Central Government, but may well occur in Local Government as well.  These alleged tax/NIC evasions seem to the writer to be due to an inevitable lack of focus by HMRC due to the widely drawn secondary legislation of HMRC, and HMRC's insufficient resources to properly police such an wide ranging system.  Clearly HMRC needs legislative change to help HMRC prioritise.

(3) The words of S.I. 2000/727 section 7(1) Step One, etc, need to be amended without any further delay, especially to minimise aggravation to small businesses to enable them to start up with some legislative certainty.

(4) In particular, to restrict cost allowances in a relevant easy to implement way in order to allow HMRC to focus their investigative resources, a ceiling of the VAT registration threshold has been chosen.

(5) Furthermore, to unambiguously avoid any possibility of any potential "Friday to Monday" type scenario, a minimum "cooling off" break from an employment 'contract for service', a minimum break period of 366 calendar days - i.e. a year - has been chosen. 

 

RECOMMENDATION: Amend the "Social Security Contributions (Intermediaries) Regulations 2000 SI 2000/727" Section 7 (1) Step One that reads: QUOTE 
7 Worker's attributable earnings—calculation
 (1) For the purposes of regulation 6(3)(a) the amount of the worker's attributable earnings for a tax year is calculated as follows:
 Step One
 Find the total amount of all payments and benefits received by the intermediary in that year under the arrangements, and reduce that amount by 5 per cent 
ENDQUOTE by replacing the words "by 5 per cent" with the following words: "by a monetary amount that is the greater of either (a) the VAT registration threshold for a worker who did not work for a period of at least three hundred and sixty six (366) calendar days after the date his or her previous contract for service if any ended or (b) five (5) per cent for all other workers".

Kind regards - dstickl

VAT?

leon0001 | | Permalink

Directors' fees billed by personal services company appear to exceed VAT registration limit. Has the company been registered?

MartinLevin's picture

Déjà vu?

MartinLevin | | Permalink

Might I, respectfully, point out that in the 1970s (yes, I’m old enough, as I started work in November 1963, and still at it, although I am enjoying life), at a “casual dinner” at a conversation between two guests: one of which was, I believe, perhaps, the Chairman of the BRITISH (that’s another story) Broadcasting Corporation, and the then Head of the “Inland Revenue” (as it was then), stated that “all our contributors are self-employed”.  This remark apparently inflamed outsiders, who consider that those contributors came from outside, used the facilities, and were not taxed at source.

Later we had tax laws about Agency Workers (probably around the 1975 Finance Act).  The introduction by the “next generation” of “IR35” was, in my view, strange, and irrelevant, as we had S38 FA 1975 (I think).  The tax yield under IR35 was not great, and the lawyers – as ever – reaped the rewards, rather than the Exchequer.

 

So, as the French would have it: déjà vu?

Is there no end to end to it

Roland St Clere... | | Permalink

Yet another example of one law for the rich and and one law for the rest of us.

I heard yesterday that the head of the Equal Opportunities Commission was being paid £200,000! 

The gravy train goes on whilst everybody else has to tighten their belts.

 

 

well at least he is operating through a recognised

justsotax | | Permalink

entity and is getting taxed accordingly (IR35 should apply?!) - unlike those MP's who are hunting him down (yes the ones who receive an allowance of £400 per month for working away from home.....try claiming that as subsistence for any 'normal' person - and as tax relief not as a tax free allowance)....

 

About time our leaders....well led from the front......don't hold your breath!

government departments

The Black Knight | | Permalink

are some of the biggest drivers and users of personal service companies.....

So we have HMRC bleeting and other government departments encouraging.

total madness...they can only assume that creating a problem and having some people running around in circles chasing that problem stimulates the economy and jobs.......sounds like a sub prime idea !!

the tax free expenses for breakfast travel dinner and tea etc etc and etc for government workers supplied through umbrella companies are amazing. !

With that backdrop I find myself ever closer to the

justsotax | | Permalink

boundaries when advising client's regarding what is acceptable or not in regard to expenses....of course the government/Mps/civil service seem able to 'create' their own special rules to suit...which inflames the situation even more - especially for those small businesses who are struggling to survive.

Tax avoidance at and from the top, perhaps?    2 thanks

dstickl | | Permalink

justsotax wrote:

....of course the government/Mps/civil service seem able to 'create' their own special rules to suit...

... would be tax avoidance at and from the top, wouldn't it?

Thieves...    2 thanks

Roland St Clere... | | Permalink

All of them.

 

HMR &C are quick to impose penalties for non compliance but when it comes to their friends in high places a nod is as good as a wink.

 

The sooner we all wake up and realise that we are not in this to gether the better. What sort of country is it that makes the least well off pay for the mistakes of the most well off.

 

 

 

Tax Law Rewrite means that IR35's S.I. 2000/727 7(1) is replaced

dstickl | | Permalink

Tax Law Rewrite means that IR35's S.I. 2000/727 7(1) Step One, etc, is replaced by ITEPA 2003, Part 2, Chapter 8, Section 54 (1) Step 1, etc, please see HMRC website: Tax Law Rewrite.   Sorry if my earlier posts were somewhat confusing due to referencing the earlier (and now superseded) SI.Tax Law Rewrite Project

The aim of the Tax Law Rewrite Project is to rewrite the UK's primary direct tax legislation to make it clearer and easier to use, without changing the law.

The project's work is overseen by two outside Committees - a Consultative Committee and a Steering Committee. More information on the Committees is available in the project's Tax Law Rewrite: Report and Plans, 2008-09 document.

To date the project has delivered - amongst others - the following

  • The Income Tax (Earnings and Pensions) Act 2003 (effective from April 2003).

 

What I find most interesting is that the words of "5 per cent" in the SI2000/727 are replaced by "5%" in ITEPA'03 but, given that the SI may not have been discussed in Parliament, it may be that the rationale for "5%" in ITEPA'03 was not discussed in Parliament either, perhaps because of a claim that a "rewrite, without changing the law" meant that discussion in 2003 was unnecessary! How sneaky can you get? Now that the brown stuff has hit the rotating machine at the DEPARTMENT OF HEALTH, perhaps the HMRC's IR35 mental constipation can cease?

Anyway, a copy of my latest letter to Messrs Cameron and Osborne will be posted shortly on the AWEB DoH thread ...

cfield's picture

They've plagiarised my website!    1 thanks

cfield | | Permalink

I thought plagiarism wasn't allowed on AccountingWeb! I am referring to the following passage in the post by dsticki on 5/2 (see Background para).

IR35 was "Originally trailed as a means of cracking down on Friday to Monday cases, where employers were sacking whole departments [on Friday], and then getting those staff to come back [on the following Monday] as independent consultants"  

I thought those words sounded rather familiar, and when I saw "e.g. see acumen accounting website " I realised they'd come straight from my website (as below).

http://www.acumen-accounting.co.uk/IR35.html 

Whilst imitation is the most sincere form of flattery, I do wish dsticki had asked me first. Then at least I could have insisted that he insert a proper link to my website, rather than the almost invisible "eg" above.

Good to know that my words are being waved in front of the Chancellor's nose though. If the OTC had heeded my advice at the time and suggested to George Osbourne that IR35 be restricted to ex-employees (apart from those properly retired), we might have a more sensible approach to the issue of tax avoidance by personal service companies in place now.

Chris

Sorry Chris - you're right, I was impressed by your words & ...

dstickl | | Permalink

Sorry Chris - you're right, I was very impressed by your words & your website, which I thought I'd adequately referred to in my mails to 10 & 11 Downton Street, following a Google search. Please note that your words may also be in subsequent letters sent to 10 & 11 etc.

Incidentally, I added the explanatory words in square brackets [thus] to make it quite clear to our MPs etc just how limited was the scope of IR35 as justified in Parliament so long ago, in order that they can have no doubt that the "IR35 scope creep" subsequently in S.I. 2000/727 Section 7 (1) Step One etc etc (interesting question: Were the full economic implications of this SI ever fully debated in Parliament, in line with the Bill of Rights?) was outside that original "Friday to Monday" widely spoken phrase, and has apparently resulted in the "disquiet" at SLC & Dept of Health ...

Chris: Now that I know how to contact you via PM, I'll certainly "ask you first" next time! Equally, if you wish to PM me, please do so, as and when.

ALSO RE: Your "If the OTC ...", would I be correct in thinking that you actually meant OTS, please? If so, you may be interested to learn that I was upset that the forward to their OTS 2011 report on IR35 had a short discussion on Simplification, but nowhere explicitly said that Simplification had to make economic sense.

My further researches indicate that the need for economic sense in taxes was recognised 15 years ago:
The Tax Law Review Committee's "TAX AVOIDANCE" report November 1997 states [section 1.9 on page 2] "Avoidance, and the risk of avoidance, are at their greatest where there is a failure to base the tax on sound economic principle, where the tax creates unsustainable boundaries or where there are arbitrary rules. If governments wish to limit avoidance, they should avoid enacting legislation that positively invites it!" The problem of the 2003 legislation [ITEPA Section 54 (1) Step 1 etc] is "there is a failure to base the tax on sound economic principle, where the tax" fails to recognise the inevitable 'higher than 5%' inevitable running costs of small business.

OR if OTS etc prefer: Taxes (like any other tariff or scale of prices) have to be formulated so as to make economic sense, to be acceptable to the HMRC 'customer'. My thesis - to OTS, HMRC & HMG - is that IR35 as set out in ITEPA 2003 just does not make economic sense, because its IR35 regime fails to recognise the levels of costs faced by small businesses - due to the "5%" of 'payments and benefits received' (pabr) being negligible at low levels of pabr.

 

SUM UP: Chris is quite correct - IF OTS had realised the wisdom last year "that IR35 be restricted to ex-employees (apart from those properly retired), we might have:

(1) a more sensible approach to the issue of tax avoidance by personal service companies in place now", AND

(2) HMG would not have had the embarrassments at Student Loans Company, and at Department of Health, and ...

(3) some extra growth to the UK economy - in GDP etc - due to the removal of some of IR35's red tape! 

cfield's picture

No worries dstickl    1 thanks

cfield | | Permalink

Thanks for your kind words. Glad you liked the website. I only hope the powers-that-be take some notice of your submissions!

Yes I did mean the OTS. It was the growing trend back in the late 1990s for employers to "outsource" operations to employees working through PSCs that was the most insiduous aspect, and it's a shame the Government and the OTS didn't focus more on this last year when deciding on the future of IR35, rather than bemoaning the tax risk, which as we now know is in no small way contributed to by them!

Personally I'm all in favour of getting senior civil servants off the payroll. At least we could then get rid of them when their contracts are up and (hopefully) not need to pay them pensions. They should be like directors of plcs and have their contracts come up for renewal every few years.

People should be careful what they wish for. If Ed Lester is on the government payroll, he will be entitled to all sorts of rights he hopefully doesn't get now, including 3% into a pension scheme come October. That would cost us even more than the lost employee NI, which would only be 2% on most of his income (the 13.8% employer NI is not lost to the Exchequer as it would be paid for out of public funds anyway).

As for tax, obviously he only pays 20% through the company, but if he extracts most of the profits as dividend he would be clobbered by even more tax in the long run than if he was an employee. It's the ability to dodge NI and claim expenses that produce most of the savings through a PSC.

If IR35 had been restricted to the Fridays to Mondays it wouldn't have stopped Ed Lester as he was never previously an employee, but it didn't stop him anyway because HMRC clearly pick and choose who they apply the IR35 rules to. This is a secretive aspect of IR35 that few are aware of, and it is very unhealthy as it is effectively one law for some people and another for everyone else.

For the few open and shut cases these days that IR35 really does apply to the 5% allowance is actually quite generous. Anyone spending more than that on their business would probably be outside the rules anyway, but not without a lot of worry, which is another insiduous aspect of IR35.

HMRC were relying on fear of what the rules MIGHT mean to rake in more tax, rather than having clear guidelines updated by case law so everyone knew. At least the new helpdesk and forum may address that aspect, although it's hard to see them playing fair to any enquirers.

One thing they should perhaps do is scrap the employer NI liability in IR35 cases or force the end user or agency to pay it. It's just not fair for people caught by these rules to pay both employee and employer NI.

I know they can always negotiate an increase with the client to cover it, but most people aren't actually aware of the employer NI issue until it's too late, and I've come across agencies who refuse to compensate contractors working through their own companies for employer NI even though they are saving the money themselves.

Anyway, I hope your efforts bear fruit as you've obviously put a lot of work into it.

Chris

franciswong's picture

Tax laws IR35  should apply

franciswong | | Permalink

Tax laws IR35  should apply accordingLy. This is prior to the employment freewill. What more for if this will no be justified what will happen to the working students?Interest rates on subsidized Stafford loans, widespread loans for university students, are set to double by July if Congress doesn’t act. Together with the rate of increase, the pace of student loan defaults is also going up along with other toxic results of increasing student debt. Article resource: Default rates going up along with student loan rates. Along with increased bills, an increase in the default rate on student loans will follow. Default rates are already high.

cfield's picture

Not an American forum

cfield | | Permalink

The last poster is clearly referring to student loans in America. For your information, this is a British forum. There are other countries in the world apart from the USA you know!

Budget 2012 stable door?

leon0001 | | Permalink

According to the Budget 2012 red book, anti avoidance measures will include:

2.207 Personal service companies and IR35

........subject to consultation, requiring office holders/controlling persons who are integral to the running of an organisation to have PAYE and NICs deducted at source by the organisation by which they are engaged. (Finance Bill 2013)” 

Web link for tonight's BBC2TV "Newsnight" programme trailer ...

dstickl | | Permalink

Tonight's BBC2TV "Newsnight" programme is trailed on BBC website with this link:

http://www.bbc.co.uk/news/uk-politics-17927792

Newsnight...

Roland St Clere... | | Permalink

Yet another example last night of how we are not all in this together!

HM R & C sanctioning arrangements that allow their friends to avoid tax

whilst sending out (incorrect) penalty notices to other tax payers.

Today on Radio 4 this morning featured a piece about the ever worsening

performance of HMR & C. I have read that the Chair of HMR & C is leaving.

How much will his pay off be? Thats on top of all the bungs he has probably

received from his friends at Vodafone, Goldman Sachs et al.

When will these people get their snouts out of our trough?

 

 

6 days left on this BBC2TV "Newsnight" programme iPlayer link:-

dstickl | | Permalink

6 days left on this BBC2TV "Newsnight" programme iPlayer link:-

http://www.bbc.co.uk/iplayer/episode/b01h7mqm/Newsnight_02_05_2012/ 

... just watch the first fifteen minutes!   Will you notice an apparent ignorance of the "fiscal horror" words of "IR35" ?

Question: is there a general ignorance of IR35 on the Parliamentary House of Commons "Public Accounts [Select] Committee", because allegedly neither Margaret Hodge MP {Chair} nor [I think, and apologies if I'm mistaken here] Richard Bacon MP {member} IMHO mentioned an IR35 aspect?